16 CFR Part 312; Children’s Online Privacy Protection Rule Review; Project No. P104503
Regarding “COPPA Rule Review, 16 CFR Part 312, Project No. P-104503”: I support these changes and further reviews to COPPA to tighten standards and protect our nation's children. I support expanding protections to the youth age group 13 to 18 years with emphasis on targeting data mining/ student tracking companies. Schools are entering into agreements with a REQUIRED student participation in a privately held national data bases containing all manner of student information. The age group of 13 to 18 years is not protected from profit seeking data mining companies that hold their grades, their names, their phone numbers, emails, their personality test results (Naviance has test offerings). College bound students are being required to participate in the Common Application, which requires that supporting documents (secondary school reports, transcripts, and recommendations) submitted electronically to Common App member colleges go through the Naviance/Family Connection system. Waiver of their FERPA student rights is routinely recommended on these common application. Both Naviance and the Common Application have a VERY strong connection through Hobsons, a company that specializes in higher education marketing including enrollment marketing. A tool to evaluate colleges is one thing. Participation of minors in a privately held database unconstrained by special protections under federal law is another. Americans age 13-18years deserve protection and coverage under COPPA. I hope lawmakers will strongly consider this age group when evaluating changes. Thank you.